The Spanish National Securities Market Commission (CNMV) has launched a public consultation process for the preparation of a Technical Guide on internal control in the management of closed-end investment vehicles, which will affect managers of private equity firms and other closed-end investment vehicles.

The aim of this initiative is to establish criteria and best practices to guide managers on key aspects such as their organizational structure, the performance of internal control functions, and the management of conflicts of interest. The forthcoming Technical Guide will specify the CNMV’s supervisory expectations in these areas and will help streamline the authorization processes for entities, providing greater legal certainty and transparency.

The public consultation — included in the CNMV’s 2025 Activity Plan — seeks to gather the opinions of individuals and entities potentially affected regarding the issues to be addressed, the objectives of the Guide, and the main application criteria, such as scope, proportionality, internal policies and procedures, and the management of conflicts of interest.

Expected benefits include:

  • Facilitating compliance with regulatory obligations related to the organization and internal control of managers.
  • Clarifying the application of the proportionality principle provided for in current regulations.
  • Providing greater transparency and clarity regarding the criteria that the CNMV will follow in its registration and supervision functions.

Interested parties may submit their comments in writing by December 15, 2025, to the email address: supervision.gtcic@cnmv.es

Once the consultation period concludes, the CNMV will publish all comments received, except in cases where confidentiality is expressly requested.

More information and the full text of the draft are available on the CNMV website: www.cnmv.es

and https://www.cnmv.es/DocPortal/DocFaseConsulta/CNMV/NP_CP_civehiculoscerrados.pdf

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